https://www.taxtmi.com/caselaws?id=92775 In central excise, manufacture had to be proved by evidence, and the Department bore the burden of showing that the goods were made by the assessee. Filter elements were not shown to have been manufactured by the assessee, as the record did not establish production by the assessee rather than by job workers, and mere non-obtaining of relaxation under Rule 51A did not prove manufacture. Machining of aluminium castings into filter heads was treated as a transformation into distinct machine parts, but liability still could not be fastened on the raw material supplier without proof that the outside processors were only hired labour. The demand was therefore unsustainable on both items. en-us Fri, 22 Oct 1999 00:00:00 +0530 Sat, 05 Nov 2011 10:36:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=92775 In central excise, manufacture had to be proved by evidence, and the Department bore the burden of showing that the goods were made by the assessee. Filter elements were not shown to have been manufactured by the assessee, as the record did not establish production by the assessee rather than by job workers, and mere non-obtaining of relaxation under Rule 51A did not prove manufacture. Machining of aluminium castings into filter heads was treated as a transformation into distinct machine parts, but liability still could not be fastened on the raw material supplier without proof that the outside processors were only hired labour. The demand was therefore unsustainable on both items. Case-Laws Central Excise Fri, 22 Oct 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=92775